Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.
Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.
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